The Tax Publishers

[1]9. Income deemed to accrue or arise in India.

(1) The following incomes shall be deemed to accrue or arise in India :

[2](i) all income accruing or arising, whether directly or indirectly, through or from any business connection in India, or through or from any property in India, or through or from any asset or source of income in India, [3][* * *] or through the transfer of a capital asset situate in India;

Explanation [4][1] : For the purposes of this clause

(a) [5][in the case of a business] of which all the operations are not carried out in India, the income of the business deemed under this clause to accrue or arise in India shall be only such part of the income as is reasonably attributable to the operations carried out in India;

(b) in the case of a non-resident, no income shall be deemed to accrue or arise in India to him through or from operations which are confined to the purchase of goods in India for the purpose of export;

[6][* * * *]

[7][(c) in the case of a non-resident, being a person engaged in the business of running a news agency or of publishing newspapers, magazines or journals, no income shall be deemed to accrue or arise in India to him through or from activities which are confined to the collection of news and views in India for transmission out of India;]

[8][(d) in the case of a non-resident, being

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